Dependent personal services are those related to employment – salaries, wages and similar remuneration. Generally, employment income is taxed in the country of residence unless it is exercised in the other country. If you perform employment duties in the other country (or in Canada if you are resident in the other country) the employment income may be taxed in the country where you performed the duties.
But, this is always a fun section, because there are many exceptions to the rule. For instance, the Canada-US tax treaty allows the income to be exempt from tax in the country where the services take place if the remuneration is $10,000 or less in the Calendar year, or if the employee is in the that country less than 183 days and the remuneration is not borne by a resident or Permanent Establishment (PE) of that country.
Another example is the Canada-Tunisia treaty where $3,000 earned in the fiscal year or if the remuneration is not borne by a resident or PE.
Still another would be the Canada-New Zealand treaty where there is no base amount but the 183 day rule and the resident/PE rule will apply.
And the list goes on, but you get the picture, there are many exceptions to the rule and you need to check the treaty.
There are also usually additional paragraphs to exempt transportation employees as well as government services to look for in any treaty.
You will also note that it says “may be taxed”. That means that the country where the employment duties are performed has the right to tax you, but your country of residence will also tax you on that amount (and, of course, give you a tax credit for the tax paid).
Remember that remuneration can be considered “borne by” a business in a country where there is a flow through situation, so be sure to look at all the details of the case. And, of course, check the details in the treaty that applies.